Apr. 20, 2022
Hi, Please rescind SR-NSCC-2022-003 for the following reasons: The proposed NSCC rule appears to protect the practice of naked short selling (the short selling of shares that have not been affirmatively determined to exist -- which, under the SEC's own position, is illegal - for which a T+3 requirement was instituted after the fallout of the 2008 financial crisis https://www.sec.gov/news/press/2008/2008-204.htm) by allowing market makers to utilize proposed SFTs as placeholders (instead of buy in of a security @ market price, the only cost becomes the delta from one day to the next) to allow Fail-to-Delivers to take place. This hurts me and my faith in markets as a retail investor, because the rule effectively creates a tool for market makers to avoid assuming financial responsibility for their already illegal practice of naked short selling and by extension, provides infinite ammo for cellar boxing - which in turn provides market makers with the ability to bankrupt any publicly traded company of their choosing. The 'Fire Sale' justification portion of the document speaks to the NSCC attempting to reduce 'market disruption', which in my view only serves to protect bad faith parties from the consequences of their own fiscal irresponsibility. Again, please dismiss SR-NSCC-2022-003, with prejudice if possible. Thanks, Tom.